Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to suppress evidence discovered by the police during the forcible detention of Defendant, holding that Defendant's detention violated his Fourth Amendment rights under Navarette v. California, 572 U.S. 393 (2014).Defendant was detained pursuant to Terry v. Ohio, 392 U.S. 1 (1968) on the basis of an anonymous telephone tip regarding "a young man that has a handgun." After Defendant was detained, the police saw him drop an object in a garbage can. A subsequent search revealed that the object was a handgun. Defendant was charged with criminal possession of a pistol and carrying a pistol without a permit. Defendant filed a motion to suppress, arguing that his detention was unconstitutional because the anonymous tip did not give rise to a reasonable suspicion that he was engaged in, or was about to be engaged in, criminal activity. Therefore, Defendant argued that the handgun was tainted as the result of his unlawful seizure. The trial court denied the motion to suppress. The Supreme Court reversed, holding that the anonymous telephone call did not give rise to a reasonable suspicion that Defendant was in possession of a handgun, justifying an investigative Terry stop. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court concluding that the improper exclusion of P's testimony during the underlying criminal proceedings was not harmless, holding that the testimony was necessary for the jury to assess the complainant's credibility, and therefore, the exclusion of P's testimony was not harmless.Defendant was charged with sexual assault in the second degree and two counts of risk of injury to a child. The trial court precluded Defendant from calling P, the complainant's longtime boyfriend, as a witness regarding his observations of certain aspects of the complainant's behavior that the State's expert witness had testified were commonly exhibited by child victims of sexual assault. The Appellate Court reversed, holding that P's testimony was improperly excluded because it was relevant to the issue of whether the complainant had exhibited behaviors associated with some sexual assault victims, which had a clear and direct bearing on the central issue in this case - whether the complainant had been sexually assaulted by Defendant. The Supreme Court affirmed, holding that the improper exclusion of P's testimony was not harmless. View "State v. Fernando V." on Justia Law

In this action brought by the administrators of the estates of nine people killed in the massacre at Sandy Hook Elementary School, the Supreme Court held that the trial court properly determined that, although the trial court properly struck most of Plaintiffs’ claims against various manufacturers, distributors and sellers of the Bushmaster XM15-E2S semiautomatic rifle, the Protection of Lawful Commerce in Arms Act (PLCAA), 15 U.S.C. 7901 through 7903, did not bar Plaintiffs’ claims that Defendants violated the Connecticut Unfair Trade Practices Act (CUPTA), Conn. Gen. Stat. 42-110a et seq., by marketing the firearm to civilians for criminal purposes and that those wrongful marketing tactics contributed to the massacre.Adam Lanza carried out the massacre using a XM15-E2S. The Supreme Court affirmed the trial court’s judgment that most of Plaintiffs’ claims were precluded by established Connecticut law and/or PLCAA. However, as to Plaintiffs’ claims that Defendants knowingly marketed, advertised, and promoted the XM15-E2S for civilians to use to carry out offensive, military style combat missions, the Supreme Court held that Plaintiffs pleaded allegations sufficient to survive a motion to strike because (1) PLCAA does not bar Plaintiffs’ wrongful marketing claims; and (2) to the extent that it prohibits the unethical advertising of dangerous products for illegal purposes, CUTPA qualifies as a predicate statute. View "Soto v. Bushmaster Firearms International, LLC" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant’s judgment of conviction, holding that the evidence was sufficient to support Defendant’s conviction for attempt to commit murder under the substantial step provision of Conn. Gen. Stat. 53a-49(a)(2) because the determination of what constitutes a substantial step focuses on what the actor has already done rather than on what the actor has left to do to complete the substantive crime.The Appellate Court concluded that there was sufficient evidence to sustain Defendant’s conviction of attempted murder after construing section 53a-49(a)(2) to require the substantial step inquiry to focus on what the actor has already done rather than what remains to be done. The Supreme Court affirmed, holding that there was ample evidence from which a jury could have determined beyond a reasonable doubt that Defendant took a substantial step to murder the intended victim. View "State v. Daniel B." on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the trial court denying Defendant’s motion to correct on illegal sentence, holding that the Appellate Court’s thorough and well reasoned opinion fully addressed Defendant’s question certified to the Supreme Court.The Supreme Court granted Defendant’s petition for certification to appeal, limited to the question of whether the Appellate Court properly concluded that Defendant’s sentence was not illegal, did not violate the Double Jeopardy Clause, and did not run contrary to legislative intent. The Supreme Court adopted the Appellate Court’s opinion as the proper statement of the issues and the applicable law concerning those issues and affirmed. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court reversing the judgments of the trial court denying the petitions filed by the maternal grandmother (Petitioner) for termination of Father's parental rights with respect to his three minor children, holding that the trial court applied an incorrect legal test to determine that Petitioner had failed to prove the lack of an ongoing parent-child relationship.Specifically, the Court held (1) the trial court erred in concluding that, under the facts of this case, it was required to depart from the usual test to determine whether a petitioner has established a lack of an ongoing parent-child relationship; and (2) the trial court’s finding that Petitioner failed to prove that allowing further time to develop a parent-child relationship would be detrimental to the best interests of the children was clearly erroneous. View "In re Jacob W." on Justia Law

The Supreme Court affirmed the judgment of the trial court for Defendants Michael Telesca and Rocco Frank, Jr. in this battle between the Danbury faction and the Waterbury faction over the control of the state’s Independent Party, holding that the trial court’s decision was timely and that the trial court properly construed Conn. Gen. Laws 9-374.In its decision, the trial court ordered Secretary of State Denise W. Merrill to accept candidate endorsements made pursuant to the 2010 bylaws of the Independent Party of CT-State Central - which, together with its officers, led the Danbury faction and filed the complaint - which, in effect, gave the Waterbury faction control over the Independent Party’s statewide nominations. The Supreme Court affirmed, holding (1) the trial court’s order of supplemental briefing and oral argument concerning its subject matter jurisdiction preserved its personal jurisdiction over the parties by stopping and later restarting the decision period, thus rendering the court’s decision timely; and (2) the trial court properly determined that section 9-374 rendered the 2010 bylaws controlling, as opposed to bylaws that the Danbury faction had previously filed with the Secretary. View "Independent Party of CT-State Central v. Merrill" on Justia Law

The Supreme Court dismissed this writ of error brought by the plaintiffs in error seeking to protect their rights with respect to the judgment of the trial court that was challenged on appeal in Independent Party of CT-State Central v. Merrill, __ A.3d __ (Conn. 2019), holding that the writ of error was moot.In its judgment, the trial court resolved a dispute between the Danbury and Waterbury factions of the state’s Independent Party by granting declaratory and injunctive relief directing Secretary of State Denise W. Merrill to accept only those endorsements made pursuant to the party’s 2010 bylaws. The plaintiffs in error were thirteen candidates for the state House of Representatives endorsed by the Danbury faction prior to the trial court’s decision. The endorsed candidates argued that the writ of error was moot because of the Secretary’s unchallenged decision to accept the Danbury faction’s endorsements with respect to twelve of them. The Supreme Court dismissed this action, holding (1) the writ of error was moot; and (2) the defendant in error’s separate request for relief was not properly before the Court. View "Independent Party of CT-State Central v. Merrill" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the decision of the trial court and sustaining Plaintiff’s appeal, holding that the hearing officer did not abuse his discretion in admitting and relying on a four-page police investigation report (the exhibit) in deciding to suspend Plaintiff’s operator’s license.The Commission of Motor Vehicles suspended Plaintiff’s operator’s license after a hearing at which the hearing officer relied on a report of the incident where Plaintiff was arrested for operating a motor vehicle while under the influence and failed a breath test. Plaintiff appealed, arguing that the report was unreliable even though it complied with Conn. Gen. Stat. 14-227b(c). The trial court rejected Plaintiff’s claim. The appellate court reversed, concluding that inconsistencies and errors in the exhibit rendered it so unreliable that its admission violated principles of fundamental fairness. The Supreme Court reversed, holding that the hearing officer did not abuse his discretion in admitting and relying on the exhibit. View "Do v. Commissioner of Motor Vehicles" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Defendants after concluding that Plaintiff did not sufficiently plead that a transaction was an auction without reserve, holding that Plaintiff’s allegations were insufficient to allege an auction without reserve.After it granted Defendants’ motions to strike the trial court rendered judgment determining that Plaintiff failed to allege that one of the defendant’s request that potential buyers of its property submit their highest and best offers constituted an auction without reserve for purposes of Conn. Gen. Stat. 42a-2-328(3). The Supreme Court affirmed, holding that Plaintiff’s allegation that the defendant used the phrase “highest and best offers,” without more, was insufficient to plead an auction without reserve. View "Restaurant Supply, LLC v. Giardi Ltd. Partnership" on Justia Law